A4S Uganda Ltd – Privacy Policy for Independent Business Owners (IBOs)

Introduction

A4S UGANDA LTD ("A4S", "we", "us", "our"), of Plot 855 Mawanda Road, Kampala, P.O. Box 204314, Kampala, Uganda, is committed to protecting the personal data of every Independent Business Owner ("IBO", "you"). This policy explains what personal data we collect when you onboard and use the A4S platform, how we use and protect it, who we share it with, and your rights.

This policy is issued in line with the Constitution of the Republic of Uganda (Article 27, the right to privacy), the Data Protection and Privacy Act, 2019, the Data Protection and Privacy Regulations, 2021, the Electronic Signatures Act, 2011, and other applicable laws of Uganda.

Who is Responsible for Your Data

A4S Uganda Ltd is the data controller. Our Data Protection Officer is Otim David, reachable at 4287dave@gmail.com.

Personal data we collect

Identity and contact data: your full name, A4S number, country, residential address, phone number, email address, and your National ID or passport details.

Onboarding and verification data: a copy of your ID, a photograph of you, your on-screen digital signature, your sponsor or referral code, and any other information needed to verify your identity and conclude your IBO agreement.

Financial data: your bank name, account number and account name, used so that amounts due to you can be paid.

Network and performance data: your sponsor (upline) and the IBOs you personally enroll (downline), your position in the network, personal and team sales volumes, orders, ranks, bonuses and incentives.

Technical data: login credentials, device information, IP address, app usage logs and timestamps.

Communications: messages with our support team, training attendance and survey responses.

How we use your data and why

We process your data only for specified, lawful purposes:

To register you as an IBO and verify your identity.
To calculate, record, display and pay your commissions, bonuses and incentives accurately.
To display limited network information (for example, names and sales volumes of your downline) within your IBO dashboard so you can manage your business.
To comply with tax, anti-money-laundering and other legal obligations.
To prevent fraud, enforce the IBO agreement and resolve disputes.
To provide training, support and service communications.
To improve the platform and analyze business performance.
To send marketing messages about products and promotions, only where you have agreed.

Legal basis for processing

We rely on one or more of the following: your consent; performance of the IBO agreement with you; compliance with legal obligations; and our legitimate interests in running and securing the business, balanced against your rights.

Who we share your data with

We do not sell your personal data. We may share it with:

Your upline and downline, limited to what is needed for network management (such as name, rank, and sales volume), and never your ID number, payout details or personal financial records.
Payment providers, mobile money operators and banks, to pay your commissions.
Service providers that host our systems, send SMS or email, or provide IT support, bound by confidentiality and data protection obligations.
Professional advisers, auditors and insurers.
Authorities, such as the Uganda Revenue Authority, courts, regulators or law enforcement, where required by law.

Transfers outside Uganda

If your data is stored or processed outside Uganda (for example, on international cloud servers), we will ensure the destination has adequate data protection safeguards, or that you have consented, as required by the Act.

How long we keep your data

We keep your data for as long as you are an IBO and for [7] years afterwards to meet tax, accounting and legal requirements, unless a longer period is required by law or needed to handle a dispute. After that we delete or anonymize it.

How we protect your data

Your data is encrypted. All personal data you give us is encrypted in transit and at rest, and your National ID copy and photograph receive particular protection: they are stored in encrypted form and are accessible only to authorized A4S staff who need them for verification or legal compliance. We also use access controls, secure hosting, staff confidentiality obligations and regular security reviews. If a breach affects your personal data, we will notify you and the Personal Data Protection Office as required by the Act.

Your rights

Under the Act you have the right to:

be informed about how your data is used;
access the personal data we hold about you;
request correction of inaccurate or incomplete data;
request deletion of data we are no longer entitled to keep;
object to processing, including direct marketing;
withdraw consent at any time (this does not affect processing already done);
lodge a complaint with the Personal Data Protection Office (PDPO) in Uganda.

To exercise these rights, contact our DPO at [email]. We will respond within [30] days. Withdrawing consent or requesting deletion of data we need to run your account or meet legal duties may affect our ability to keep you as an active IBO or pay commissions.

Your responsibilities

You confirm that the information you give us is accurate and up to date. If you collect personal data of prospects, customers or your own recruits while doing business, you must handle it lawfully, use it only for A4S business, keep it secure, and not share it without the person's consent. Keep your login details confidential.

Children

The IBO program is only for persons aged 18 and above. We do not knowingly collect data from children.

Commissions and system records

A4S reserves the right to calculate all commissions, bonuses and incentives in accordance with the A4S Compensation Plan, as amended from time to time. Your entitlement is limited to the amounts generated by the A4S system. You may not claim any specific or projected amount other than what the system generates. If you believe a record about you is inaccurate, you may ask our Data Protection Officer to review it, as explained in section 10.

Changes to this policy

We may update this policy from time to time. We will notify you through the platform, email or SMS, and the latest version will always be available at [link].

Contact us

A4S UGANDA LTD
Plot 855 Mawanda Road, Kampala
P.O. Box 204314, Kampala, Uganda
Email: a4suganda@gmail.com | Phone: +256 792 124 391
Data Protection Officer: Otim David, 4287dave@gmail.com

IBO Consent and Acknowledgement

By continuing to sign up, you agree to the following conditions:

I confirm that I am 18 years or older, and I have read and understood the A4S Uganda Ltd Privacy Policy.

I consent to A4S Uganda Ltd collecting and processing my personal data, including my name, address, phone number, email, country, A4S number, National ID details, photograph, digital signature and bank details, to register me as an IBO and to pay amounts due to me.

I understand that my National ID, photograph and digital signature are stored in encrypted form and are used only for verification, contracting and legal compliance.

I understand that my name, rank and sales volumes may be visible to my upline and downline within the platform, as explained in the policy.

I understand that my data may be shared with payment providers, service providers and authorities as described in the policy, and may be stored outside Uganda with appropriate safeguards.

I understand and agree that A4S Uganda Ltd calculates all commissions according to its Compensation Plan, and that I may only claim the amounts generated by the A4S system.

I understand and agree that the Telephone number registered in the A4S system at onboarding is the only number my commission is to be paid to through mobile money.

I understand and agree that I will be paid as per the payment cycle of A4S system payout program.

I understand and agree that I I have 48 hours to transfer E-COM to E-WALLET.

I agree to receive marketing, promotional and training communications by SMS, email, WhatsApp or phone.

← Back to sign up